21.A.804 Identification of parts, appliances, and control and monitoring unit (CMU) components

It is not the intent of 21.A.804(a)(1) to introduce an obligation for a production organisation (manufacturer) to mark new parts or appliances with information which is not identified by the design approval holder. Therefore, the physical marking of parts and appliances is only required when established by the design approval (TC, STC, ETSO, repair, change) holder. For designs (TC, STC, ETSO, repair, change) approved after 28 December 2009 (the date of entry into force of Commission Regulation (EC) No 1194/2009), the design approval holder is required to identify to the manufacturer how the marking in accordance with 21.A.804(a)(1) should be done. This can be limited to identifying a marking field, possible depth and/or means etc., without prescribing the actual text or symbols to be used.

EUROPEAN PARTS APPROVAL (EPA) MARKING FOR REPAIR PARTS The EPA marking only applies to the parts, specifically designed or modified for the repair, to be incorporated as part of the repair design. If the repair scheme does not require the addition of any new parts or the use of modified parts, there is no need to mark the repaired part with the letters ‘EPA’.

EASA AGREEMENT FOR THE DESIGN APPROVAL HOLDER TO DEROGATE FROM POINT 21.A.804(a) A design approval holder may apply point 21.A.804(a) or make use of the derogation defined in point 21.A.804(b) by clarifying, in the relevant procedures, the conditions (e.g. the minimum dimensions of a (flat) area on a part suitable for marking) in which the marking on the part may be completely or partially omitted. This can also be supported by examples of parts or cases when certain parts do not have to be marked. In such cases, the relevant design data (e.g. drawings) should specify the contents and location of the information that could not be marked on the part (i.e. the information to be provided in the authorised release document or on the container).